Fire safety in a design and access statement

A design and access statement is not where a fire strategy lives, but it is where a planning officer first sees whether fire safety and inclusive access have been designed together or bolted on afterwards. For most schemes the fire safety content of a design and access statement is short: how people get in, how they get out, how the layout supports evacuation for people who cannot use stairs, and where the detail is dealt with under a separate consent. Getting that boundary right saves an awkward round of questions at validation.

Article 9 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 sets out when a statement is required, which covers major development and development in a conservation area or World Heritage Site above modest thresholds. The Order asks for design principles and concepts, and for an explanation of how access issues have been handled. Fire is not named. Access and escape are two halves of the same movement problem, so the sensible reading is that escape belongs in the access narrative.

What the statement should actually say about access and escape

Describe the movement strategy in plain terms. Where the entrances are, how someone arrives on foot, by bicycle and by car, how a wheelchair user reaches the front door without a step, how a fire appliance reaches the building and where it stands.

Then describe leaving. Number of stair cores, whether the design assumes stay put or simultaneous evacuation, where the refuges are, whether an evacuation lift is provided and how the management arrangements are expected to work. Two or three paragraphs, with a drawing reference against each claim.

What officers do not want is a paragraph saying the scheme will comply with Part B and Part M. That sentence carries no information. It also tends to be the first thing an objector quotes back.

Inclusive access and evacuation belong in the same section

Splitting them produces schemes where the accessible entrance is nowhere near the protected route, or where the refuge is a landing that a wheelchair cannot turn in. Keep them together and the conflicts surface while the plan can still change.

The things worth setting out are practical. Step-free routes from the street to every core. Level thresholds at entrance doors, and what happens where a flood-driven finished floor level lifts the ground storey above the pavement. Refuge locations and dimensions. Whether evacuation lifts are provided and to which standard. Communication between a refuge and the management point. Accessible dwellings distributed across floors rather than clustered on the ground storey because escape was easier there.

And say who advised on it. A statement that names the access consultant, or records a session with the council's access officer, reads as a designed outcome.

Where the fire statement takes over

For a relevant high-rise residential building, Article 9A of the same Order requires a fire statement on the form published by the Secretary of State, and the Health and Safety Executive is consulted at Planning Gateway One. That document deals with fire safety matters that affect the planning decision: site layout, access for fire appliances, water supplies, external wall build-up and the principles of the escape strategy.

Where a fire statement is required, the design and access statement should not attempt the same content. It should say that a fire statement accompanies the application, summarise the movement consequences in one short paragraph and cross-refer. Duplication is worse than silence here, because two documents drafted at different dates will eventually disagree, and the gateway consultee will notice.

A fire statement must be prepared by someone with the fire engineering competence to stand behind it. The same is true of a fire safety strategy to BS 9991 or BS 9999. An AI-assisted draft is a starting point for that professional, not a substitute for them, and both documents are ones where qualified professional input is required rather than merely advisable.

Thresholds, refuges and the routes between them

Three details generate most of the officer comments.

1. Level thresholds. Where the ground storey is raised for flood resilience, the ramp or the regraded approach has to be shown on the site plan, not promised in text. A 1 in 20 approach eats a surprising amount of front garden.
2. Refuge provision and size. A refuge that blocks the stair width when occupied is not a refuge. Show the clear dimensions.
3. Fire appliance access and hardstanding. Turning circles and standing positions have to coexist with tree root protection areas, bin stores and visitor parking. On tight sites this is usually what forces the layout.

Add to that the stair strategy. The requirement for a second staircase in tall residential buildings changed the plan form of a great many schemes, and the reasoning behind second staircases above 18 metres is worth reading before you fix a core layout. Sprinkler expectations also start lower than many designers assume, and the 11 metre trigger for sprinklers in blocks of flats changes floor plate efficiency more than it changes cost.

Showing the design process rather than the outcome

The Order asks how access issues have been dealt with, which is a process question. Statements that answer it well tend to include a short sequence: what the constraint was, what options were tested, why one was chosen, what was given up.

A worked illustrative example. On a constrained corner plot with a single vehicular access, the first layout placed the accessible parking bay furthest from the core because it fitted the turning head. The revised layout moved the turning head, shortened the accessible route to under 20 metres and lost one standard bay. That is three sentences, and it tells an officer more than a page of compliance language.

Photographs and diagrams carry this better than prose. A route diagram with the step-free path, the refuge positions and the appliance standing position on one sheet answers half the likely questions.

Where statements get criticised

The recurring criticisms are consistent across authorities. Access sections written as a list of standards with no site-specific content. Escape strategies described in a way that contradicts the submitted plans. Refuges shown on a general arrangement drawing but absent from the statement. Statements dated months before the drawings they describe.

One more, and it is the most avoidable. Where the application also covers information that will later form part of the golden thread of building information, inconsistencies between planning and building control submissions are now much easier to spot. What planning contributes to that record is limited but real, and the article on the golden thread sets out the boundary.

Keeping the two documents in step

Write the fire statement first where one is required, then write the access narrative around it. Agree a single set of drawing references. Date both on the same day. Put the escape assumptions in one document only and cross-refer from the other.

If the scheme changes after submission, reissue both. A revised plan with an unrevised statement is the most common reason an officer asks for a resubmission rather than an amendment.

Enter your postcode on PlanScope to see which supporting documents your scheme is likely to need before you start drafting.

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